In August 2016, the U.S. Treasury Department issued proposed regulations under IRC Section 2704 that would ratchet up the cost of maintaining family ownership of private businesses.

While practitioners are by now familiar with the Section 2704 proposed regulations, MPI provides a discussion of certain economic realities that cannot be overlooked. Check back to this section as we continue to research, write about and monitor the latest developments.

Musings From the Section 2704 Trail: “On Your Deathbed, You Will Receive a Phantom Asset”

Read our article to keep up with the shifting interpretations and potential consequences of Section 2704 that we’re discovering in our travels.

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The Wall Street journal WebReprint

Section 2704 WSJ Editorial

This editorial in the September 6th Wall Street Journal, titled “A Stealth Death Tax Increase,” looks at the motivations driving Section 2704 regulations.

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MPI Comments on Proposed IRS Regulations

After more than a year of speculation and rumors, on August 4, the Internal Revenue Service (“IRS”) issued proposed regulations under Internal Revenue Code §2704 (the “Proposed Regs”). Clearly, the goal of the Proposed Regs is to limit (or eliminate outright) the application of discounts for lack of control and lack of marketability when valuing interests in family controlled entities for gift, estate and generation-skipping tax purposes.

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Contact MPI

Contact us for more insights on Section 2704 Regulations or to learn what MPI can do for you:

Direct Contact:
Daniel M. Kerrigan, CFA, ASA
212-390-8319 |